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CMS

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Caregiver supporting sick elderly man in the wheelchair during stay in the hospice

The U.S. Department of Health and Human Services (HHS), through the Centers for Medicare and Medicaid Services (CMS), announced the new Guiding an Improved Dementia Experience (GUIDE) Model. The purpose and goal of this model is to improve the quality of life for people living with dementia, reduce strain on unpaid caregivers, and help people remain in their homes and communities through a package of care coordination and management, caregiver education and support, and respite services.

Through the GUIDE Model, CMS will test an alternative payment for participants who deliver key supportive services to people with dementia, including comprehensive, person-centered assessments and care plans, care coordination, and 24/7 access to a support line. Under the model, people with dementia and their caregivers will have access to a care navigator, who will help them access services and supports, including clinical services and non-clinical services such as meals and transportation through community-based organizations.

The GUIDE model supports President Biden’s Executive Order that directed HHS to develop a new health care payment and service delivery model focused on dementia care that would include family caregiver supports.

There is a web page that has been created specific to this care model that provides additional information, including a link to a webinar that will provide an overview of this care model scheduled for August 10, 2023:

CMS will release the application for GUIDE, a voluntary, nationwide model, in the fall of 2023. Prior to the application release, interested organizations are encouraged to submit Letters of Intent to CMS by September 15, 2023. The model will run for eight years beginning July 1, 2024.

If you are interested in receiving additional information, updates or have questions about the GUIDE model, please send an email to the GUIDE Model team’s inbox.

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Deputy Secretary Ahrens announced that in response to public comments regarding proposed waiver amendments, the Office of Developmental Programs (ODP) has adjusted the payment schedule for Recovery and Expansion incentives for CPS providers. This change has been submitted to the Centers for Medicare and Medicaid Services (CMS) for approval with the full waiver amendments. If approved, the following schedule will be implemented:

Additional updates Deputy Secretary Ahrens provided at the Medical Assistance Advisory Committee meeting can be found here.

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On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that announces and solicits public comments on proposed policy changes for Medicare payments under the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) and other Medicare Part B issues, effective on or after January 1, 2024.

The calendar year (CY) 2024 PFS proposed rule is one of several proposed rules that reflect a broader Administration-wide strategy to create a more equitable health care system that results in better access to care, quality, affordability, and innovation.

The proposed modifications include several pertaining to telehealth policy in the Medicare program for 2024. One of the major takeaways from the proposed 2024 PFS is the clarification that certain telehealth flexibilities that were previously extended until 151 days after the end of the public health emergency (PHE) have now been extended until December 31, 2024, in accordance with amendments made by the Consolidated Appropriations Act, 2023. These extensions have been known since the CAA’s passage in December last year and has also been addressed in a series of fact sheets and FAQ documents.

However, there were also some new changes addressed in the 2024 PFS. For example, every year CMS will consider adding new services to their list of codes that are reimbursable via telehealth. While they did not decide to add any new codes on a permanent basis to the list (though many remain on the list temporarily through the end of 2024), they did propose to add a number of codes to Category 3 (CMS’ current temporary list), including certain codes for health and well-being coaching services. Additionally, CMS announced a proposed revision to their telehealth code classification process, moving from a Category 1, 2 and 3 classification system to a binary ‘permanent’ or ‘provisional’ classification in an attempt to simplify the process beginning in CY 2025. In order to make the steps for getting a code accepted for inclusion in either the permanent or provisional telehealth lists transparent, CMS proposes a five-step process that is detailed in the proposed 2024 PFS, which includes consideration of the evidence of clinical benefits.

A few additional changes proposed in the document are listed below:

  • The list of telehealth practitioners is amended to recognize marriage and family therapists and mental health counselors as telehealth practitioners, effective Jan. 1, 2024.
  • CMS will pay for place of service (POS) 10 at the non-facility PFS rate, while 02 will be paid at the facility rate beginning Jan. 1, 2024.
  • Frequency limitation would be removed for subsequent inpatient visits through the duration of CY 2024.
  • Multiple clarifications are provided for billing both remote physiologic monitoring (RPM) and remote therapy monitoring (RTM) codes.
  • Direct supervision is allowed to include real-time audio video interactive telecommunication through Dec. 31, 2024 (including for FQHCs and RHCs). Direct supervision requirements are also addressed for occupational therapists in private practice (OTPP) and physical therapists in private practice (PTPP) for unenrolled physical and occupational therapists when providing remote RTM.

CMS will be accepting comments on their proposals until 5:00 pm EST on September 11, 2023, and RCPA will review the document and work with the National Council for Mental Wellbeing in drafting recommendations. We welcome provider feedback and comments to be included and ask that you contact and share these with your RCPA Policy Director.

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The Centers for Medicare and Medicaid Services (CMS) released a revised Medicare Learning Network (MLN) fact sheet on telehealth services. A number of changes have been made due to the end of the public health emergency (PHE), including the following items:

  • Information on the end of the COVID-19 public health emergency as well as CY 2023 and telehealth policies.
  • Status of Ongoing Flexibilities:
    • Through December 31, 2024, all patients can get telehealth wherever they are located. They do not need to be at an originating site, and there are no geographic restrictions.
    • Through December 31, 2024, all providers who are eligible to bill Medicare for professional services can provide distant site telehealth.
    • For behavioral or mental health telehealth, you may use 2-way, interactive, audio-only technology. This is also part of the PA Telehealth Statute under Act 98.
  • Additional Resources Provided:
    • Chapter 12, Section 190 of the Medicare Claims Processing Manual
    • Telehealth Policy Changes After the COVID-19 PHE
    • Tips for Telehealth Success
  • Added information on:
    • New G-codes. Starting January 1, 2023, you may voluntarily report the use of telehealth technology in providing home health (HH) services on HH payment claims. See MLN Matters Article MM12805 for more information.
    • Consent for care management and virtual communication services.

Providers are encouraged to review this document closely and bookmark it for future reference.

As RCPA continues its efforts to expand access via telehealth in Pennsylvania, we will be submitting comments on the new Calendar Year (CY) 2024 Physician Fee Schedule (PFS). RCPA will be sending out a communication on this in the coming days.

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The Centers for Medicare and Medicaid Services (CMS) has released a number of additional and updated documents related to the inpatient rehabilitation facility (IRF) review choice demonstration (RCD). Included in these documents are:

  • An updated and revised Operational Guide — Clarifies key programmatic details regarding the different review choices and other facets of the demonstration.
  • Frequently Asked Questions Document — The FAQ focuses on major areas of confusion on the choice selection and submission processes, the Pre-Claim Review Track, and medical necessity determinations.
  • Transcript and Recording — From the June 27, 2023, special open-door forum on the IRF RCD.

Additional information about the IRF RCD can be found on the CMS IRF RCD web page.

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The Centers for Medicare and Medicaid Services (CMS) conducted a special open door forum on June 27, 2023, that focused on the Review Choice Demonstration (RCD) for inpatient rehabilitation facilities (IRF). Beginning August 21, 2023, the RCD will begin for IRF services in Alabama. CMS has shared that IRFs in Pennsylvania will be included in the next phase of the demonstration. For additional information, there is an RCD web page dedicated to this. The presentation from the June 27 special open door is also available.

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As part of its commitment to advancing health equity and access to care for underserved populations, CMS released a set of resources addressing the needs of adults with intellectual and developmental disabilities (I/DD) living with and cared for by aging parents or guardians. The release includes resources for state Medicaid and partner agencies to provide new or additional support to adults living with I/DD and their caregivers as they age and experience life transitions.

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